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VALIDATION

GUIDELINE

Purpose
To provide guidance to both Industry and NOPSEMA assessors on the validation process as required
by the Commonwealth Offshore Petroleum and Greenhouse Gas Storage (Safety) Regulations 2009
[OPGGS(S)] and any relevant State or Northern Territory equivalents where powers have been
conferred on NOPSEMA (currently only Victoria).

Scope
This Guideline is applicable to:

all proposed facilities, including facilities that are pipelines, located in Commonwealth and
relevant State and Northern Territory designated coastal waters where powers have been
conferred on NOPSEMA; and

existing facilities, including facilities that are pipelines, located in Commonwealth and relevant
State and Northern Territory designated coastal waters where powers have been conferred on
NOPSEMA, to which a significant change (e.g. modification or decommissioning) is proposed.

Note that validation of facilities that are pipelines located in State designated coastal waters, other
than Victorian designated coastal waters, is generally a matter for the relevant State Authority.
In accordance with OPGGS(S) Regulation 2.40 (1), validation may be requested for:

a proposed facility; or

a proposed significant change to an existing facility.

It should be recognised that validation is linked to the safety case or revised safety case decisionmaking process in accordance with the following:

For a proposed facility, i.e. a facility new to the regime, a safety case is required to be
submitted to NOPSEMA, and prior to that submission, it is NOPSEMA policy to request a
validation of the proposed facility. Acceptance of the safety case is then contingent on a
satisfactory validation.

For an existing facility, if an operator proposes to significantly change the facility (e.g. modify or
decommission the facility), and where the safety case in force does not address that proposed
modification or decommissioning, a safety case revision is required. Associated with that
revision, and if NOPSEMA becomes aware of the proposed modification or decommissioning, it
is NOPSEMA policy to request a validation of the significant change. If NOPSEMA does not
become aware of the proposed modification or decommissioning, there is still a legal obligation
on the operator to gain agreement on the scope of validation for the proposed modification or
decommissioning prior to submission of the revised safety case. Acceptance of that revised
safety case is then contingent on a satisfactory validation.

Validation is focussed on safety-critical hardware, firmware and software, not processes and
procedures.

Policy
Where the Regulations state that NOPSEMA may request a validation, it is NOPSEMA policy that
validation will be requested. Refer to NOPSEMA Policy N-04200-PL0286 Validation.

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Validation

4
4.1

Guidance
Introduction
The validation is required to be a statement in writing by an independent validator regarding the
agreed matters (design, construction, installation) to the extent covered by the scope of validation
developed by the operator and agreed by NOPSEMA.
Note that the validation relates to the facility (i.e. hardware, including process control hardware or
its software equivalent) and not the activities undertaken at the facility or the procedures that
manage those activities.
The validation must establish, to the level of assurance reasonably required by NOPSEMA, that:

4.2

for a proposed facility, the facility incorporates measures that will protect the health and
safety of people at the facility, and that those measures are consistent with the formal safety
assessment (FSA) for the facility; and

for a significant change to an existing facility, that after any proposed change or changes the
facility incorporates measures that will protect the health and safety of people at or near the
facility.

Purpose
The purpose of this guidance is to assist operators to prepare a scope of validation for agreement
by NOPSEMA, which will enable them to submit an appropriate validation statement that will
demonstrate that appropriate measures have been taken protect health and safety of persons, and
where appropriate, will be consistent with the formal safety assessment for the facility.

4.3

Summary of legislative requirements


All references listed in this guidance are to Commonwealth Offshore Petroleum and Greenhouse
Gas Storage (Safety) Regulations 2009 unless otherwise specified. Equivalent provisions exist in
relevant State and Northern Territory legislation administered by NOPSEMA.
OPGGS(S) Requirements
Regulation
2.24 (4)

Safety case to be submitted to NOPSEMA


The operator must not submit the safety case before the operator and NOPSEMA
have agreed on the scope of the validation for the facility.
It is the operator who must arrange for agreement of the scope to be reached with
NOPSEMA, and this must be done prior to submission of the safety case.
Note: regulation 2.24(5) allows submission of a safety case prior to agreement of a scope of
validation for a facility in certain limited circumstances.

2.26 (1)(d)

Acceptance or rejection of a safety case


NOPSEMA must accept a safety case if in a case in which NOPSEMA has requested
a validation of the facility:
(i) the person, or each person, undertaking the validation meets the criteria
specified in subregulation 2.40 (5); and
(ii) the validation complies with regulation 2.40.
One of the criteria for acceptance of a safety case is that the validator and the
validation submission meet the requirements of the regulations.

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OPGGS(S) Requirements
Regulation
2.30 (3)

Revision of a safety case because of a change of circumstances or operations


If a circumstance mentioned in subregulation (1) or (2) is satisfied because the
operator proposes to modify or decommission the facility the operator must not
submit the revised safety case before the operator and NOPSEMA have agreed on
the scope of the validation of the proposal.
If a safety case revision is required due to a proposal to modify or decommission a
facility, then agreement on the scope of validation must be reached prior to
submission of the revised safety case.

2.34 (1)(d)

Acceptance or rejection of a revised safety case


NOPSEMA must accept a revised safety case if in a case on which NOPSEMA has
required a validation relating to a proposed modification:
(i) the person, or each person, undertaking the validation meets the criteria
specified in subregulation 2.40 (5); and
(ii) the validation complies with regulation 2.40.
One of the criteria for acceptance of a revised safety case is that the validator and
the validation submission meet the requirements of the regulations.

2.40 (1)

Validation of design, construction and installation, significant modification or


decommissioning of a facility
NOPSEMA may, by notice in writing, require the operator of a proposed facility, or
an existing facility, to provide a validation:
(a) in respect of the proposed facility; or
(b) in respect of a proposed significant change to an existing facility.
NOPSEMA may request a validation.

2.40 (2)

Validation of design, construction and installation, significant modification or


decommissioning of a facility
A validation of a proposed facility is a statement in writing by an independent
validator in respect of the design, construction and installation (including
instrumentation, process layout and process control systems) of the facility, to the
extent that these matters are covered by the scope of the validation agreed
between NOPSEMA and the operator.
Validation is a statement in writing by an independent validator. The validation
must be consistent with the agreed scope.

2.40 (3)

Validation of design, construction and installation, significant modification or


decommissioning of a facility
A validation of a proposed significant change to an existing facility is a statement in
writing by an independent validator in respect of the proposed change, to the
extent required by the scope of the validation agreed between NOPSEMA and the
operator.

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OPGGS(S) Requirements
Regulation
2.40 (4)

Validation of design, construction and installation, significant modification or


decommissioning of a facility
The validation must establish, to the level of assurance reasonably required by
NOPSEMA:
(a) in the case of a proposed facility that the design, construction and
installation (including instrumentation, process layout and process control
systems) of the facility incorporate measures that:
(i) will protect the health and safety of persons at the facility; and
(ii) are consistent with the formal safety assessment for the facility; and
(b) in the case of an existing facility that, after any proposed change or
changes, the facility incorporate measures that will protect the health and
safety of persons at the proposed facility.
The validation must provide assurance that the facility or the significant change,
provides for the health and safety of people and, where relevant, is consistent with
the FSA.

2.40 (5)

Validation of design, construction and installation, significant modification or


decommissioning of a facility
An operator who has provided material for a validation must satisfy NOPSEMA that
each person who undertook the validation had the necessary competence, ability
and access to data, in respect of each matter being validated, to arrive at an
independent opinion on the matter.
The operator must satisfy NOPSEMA as to the validators independence,
competence, ability and access to data.

4.4

The validation process


Validation is primarily a process undertaken by an independent competent party, namely the
Validator, to ensure that the design, construction and installation of safety-critical hardware,
firmware and software (including instrumentation, process layout and process control systems) of
the facility incorporate appropriate measures that will protect the health and safety of persons at
the facility. It is an assurance activity that may be requested by NOPSEMA as per Regulation 2.40.
Specifically, it is a statement in writing by the Validator in respect to the design, construction and
installation (including instrumentation, process layout and process control systems) of a proposed
facility, or significant change to an existing facility, to the extent required by the scope of validation
developed by the operator and agreed by NOPSEMA.
Validation, as referred to in the legislation, should not be confused with verification. Verification
generally requires someone to check that, for example, safety-critical equipment has been installed
correctly and in-situ is fit for its function and use. The inclusion of elements of verification within a
validation scope is potentially problematic, particularly for fixed facilities.
For example, verification that a piece of safety-critical equipment is fit for its function and use often
can only be conducted once the equipment has been installed. However, this equipment cannot be
installed until a safety case, which provides for the installation of equipment, has been accepted by
NOPSEMA, and any acceptance of a safety case related to such a proposed modification to a facility
can only occur if the operator has provided a suitable validation statement as part of the safety
case assessment process.

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Consequently, verification is a separate and distinct process from validation and generally should
be addressed within the safety case for the facility rather than coupled with validation. Regulations
on safety case contents requirements, such as Regulation 2.12, 2.14(2), 2.18 and 2.22(3), detail
verification requirements that must be addressed in the safety case for a facility. Validation is a
separate assurance process, provided for by the regulations and tied to safety case decisionmaking. It is essentially a three step process as discussed below.

4.4.1 Requesting validation


NOPSEMA may, by notice in writing, require the operator of a proposed facility, or an existing
facility, to provide a validation in respect of the proposed facility, or in respect of a proposed
significant change to an existing facility [OPGGS(S) Regulation 2.40(1)].
Operators should note that is NOPSEMAs policy to request a validation in respect of all proposed
facilities and all significant changes to existing facilities resulting from a proposal to modify or
decommission that facility.
It is clear that for a proposed facility there must first be a registered operator before NOPSEMA is
able to request a validation of that proposed facility. Operator nomination and registration is
therefore the first step to be undertaken by the proponent.
Operators may choose to undertake third party validation of their proposed facility or proposed
significant change to their existing facility, however under the Regulations, unless NOPSEMA
formally requests a validation, they do not need to submit any validation material to NOPSEMA for
consideration as part of the safety case assessment process [OPGGS(S) Regulation 2.26(1)(d) and
2.34(1)(d)].
Notwithstanding the above, this does not excuse the operator from the requirement to gain the
agreement of NOPSEMA on the scope of validation prior to submission of a safety case [OPGGS(S)
Regulation 2.24(4)] or revised safety case [OPGGS(S) Regulation 2.30(3)]. Note: NOPSEMA may
formalise the request for validation, in accordance with OPGGS(S) Regulation 2.40, as part of
agreement of a scope of validation in accordance with OPGGS(S) Regulation 2.26(1)(d) or
2.34(1)(d).

4.4.2 Agreement of scope of validation


Once a validation has been formally requested, NOPSEMA and the operator are required to agree
the scope of validation, prior to submission of the safety case or safety case revision [OPGGS(S)
Regulation 2.24(4)] or revised safety case [OPGGS(S) Regulation 2.30(3)]. The proposed scope of
validation needs to be commensurate with the activities described within the safety case for which
acceptance is being sought. The scope of validation document should be accompanied with a
completed Proposed Scope of Validation Submission Cover Sheet, form N-04200-FM0880.
While there is no formal provision for NOPSEMA to deal with the validator on agreement of the
scope, NOPSEMA recognises the benefit of early discussion between operators and their preferred
validators. It is often beneficial for operators to involve the validator early in the process, prior to
seeking agreement from NOPSEMA to the scope of validation, such that the operator can gain
some level of assurance from the validator that the codes and standards selected for the proposed
scope are likely to be appropriate to the items being validated.
See section 4.6 below for further discussion on scope of validation.

4.4.3 Submission of the validation


The validation must be complete and submitted to NOPSEMA along with information with respect
to the validator, in order to permit a decision to be reached on the safety case [OPGGS(S)
Regulation 2.26(1)(d)] or revised safety case [OPGGS(S) Regulation 2.34(1)(d)]. An operator of a
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facility may only undertake activities in relation to that facility if there is a safety case in force for
the facility that provides for those activities. Therefore, for activities relative to the design,
construction, and installation of a proposed facility to be undertaken, it follows that the safety case
for the construction and installation stage must be in force.
In order for the safety case to be accepted, there has to have been a validation compliant with the
Regulations that is aligned with the scope/stages in the life of the safety case.

4.5

Timing

4.5.1 The timing of validation


For a proposed facility, i.e. a facility new to the regulatory regime, the following steps are offered as
a guide to how validation fits into the requirements of other regulations:
Operator nomination and registration.
NOPSEMA requests validation.
NOPSEMA / Operator reach agreement on the scope of validation, i.e. what safety-critical
elements of the facility are required to be validated and against which codes and standards
(including validator confirmation of the appropriateness of those codes and standards).
Consideration should be given to:

The timescale for when the validation of these elements is required in order to progress
the safety case decision-making process;

The nature and credit assigned, regarding validation, of any relevant marine certification;

The form of the validation deliverable (e.g. statement, report or certificate); and

It is also prudent at this stage to agree the actual validator(s) so as to address the
requirements of OPGGS(S) Regulation 2.40 (5) with regard to competence and
independence.

The scope of validation is agreed by NOPSEMA in writing.

Operator submits facility safety case.

Safety Case Assessment / validation underway.

Validation delivered.

Safety case decision-making.

4.5.2 Timing of validation with respect to safety case acceptance


The requirement for validation clearly impacts on the timing of the submission of the validation and
safety case documentation by the operator. For example, depending upon the nature of the
facility, it may be necessary for the design and construction validation to be completed and
submitted before the safety case for the installation stage in the life of the facility can be accepted.
Likewise, it may be necessary for the installation validation to be completed and submitted before
the safety case for the operations stage in the life of the facility can be accepted.
For the purposes of the regulations, the validation submission may need to be provided in stages in
order to permit safety case acceptance, however this depends on how an operator chooses to
stage their submissions under the regulations. This should be clearly understood and agreed at the
scope of validation agreement stage.
In some circumstances it may not be possible for an operator to submit documentation necessary
for NOPSEMA to be satisfied about the validation in a timely fashion. This may potentially lead to
delays in acceptance of the safety case.

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In order to avoid unnecessary delays, NOPSEMA and the operator must be clear on what safetycritical elements of the facility need to be validated and when. This should be clearly reflected in
the agreed scope.

4.6

Scope of validation General requirements


Once validation is requested, the operator should consider engaging with the validator to gain
some assurance that the codes and standards selected as part of the proposed scope of validation
are likely to be appropriate for the selected scope items. The operator should then engage with
NOPSEMA with a view to agreeing the scope of validation. The scope of validation will generally
vary depending on the particular circumstances and the stage in the life for which safety case
acceptance is being sought, however any item which is intended to be employed as safety-critical
equipment and will be installed on a facility during a particular stage in the life of a facility, even if it
will not be employed as safety-critical equipment during that particular life stage, should be
included in the scope of validation.
NOPSEMA generally suggest that, as a minimum, operators use the safety-critical systems identified
in the validation matrix (N-04200-FM0325), as the basis for their proposed scope of validation. The
operator should consider these elements and develop a scope tailored to the particular project or
stage in the life of the facility noting that, as a general rule, anything that is intended to be installed
which will subsequently be safety-critical needs to be included in the scope of validation. A number
of factors should be considered by the operator in developing the proposed scope of validation.
These are discussed below.
The scope of the safety case, including the activities it covers and the equipment to be installed,
determines which equipment must be validated before a safety case, for a particular stage in the
life of the facility, can be accepted. The focus should be on equipment to be installed at that stage
in the life of the facility, a failure of which, would pose a high risk to personnel (e.g. can result or
contribute to an MAE), even if that equipment is not to be used during that particular stage in the
life of the facility.
For a proposed facility, the selection of elements for validation should be based on the findings
from the Hazard Identification and Risk Assessment processes undertaken as part of the Formal
Safety Assessment (FSA) to identify Major Accident events (MAE) and hence safety-critical elements
of the facility that provide barriers to those identified MAEs. It is these safety-critical elements that
should be subject to validation. However, for facilities which are likely to have safety cases for
various stages in their life e.g. construction, installation, operation, etc. where safety-critical
equipment is constructed and/or installed but is not going to be used for the particular stage in the
life of the facility for which the safety case is submitted, it is important that these items are
included in the proposed scope of validation. The reason this is important is because the
requirement for validation is only triggered for new facilities, and for modification or
decommissioning of existing facilities. Consequently, the transition into an operational stage in the
life of a facility (including commissioning) does not in itself trigger the requirement for validation.
The Hazard Identification and Risk Assessment processes will ultimately form the basis of the FSA
described in the safety case for the facility (see notes below on Consistency with FSA). For a
validation of a proposed significant change to an existing facility, the elements selected to comprise
the proposed scope of validation should be based on the following principles:

Any previously validated elements of the existing facility affected by the significant change
proposed should be reselected for validation;

Any new equipment to be installed on the existing facility as part of the significant change that
falls into the categories of equipment already subject to validation should be selected for
validation; and

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Any new equipment to be installed on the existing facility as part of the significant change that
is identified by the risk assessment as being safety-critical should be selected for validation,
including equipment installed for use during a subsequent stage in the life of the facility.

4.6.1 Scope of Validation Contents


It is beneficial if the scope of validation is not just a simple list of the identified safety-critical
elements of the facility to be validated, but contains additional information on the following.

4.6.1.1 Overview of the proposed new facility or modification, and lifecycle


This should be a high level review of the proposed new facility or modification, and need not be
overly detailed. Consideration should be given to including a drawing or pictorial representation as
this can aid NOPSEMAs understanding of the proposal.
While not necessary, some description of the reason for a modification can provide context to
NOPSEMA.

4.6.1.2 Systematic process for the selection of the safety-critical validation items
Within the scope of validation, the process for selection of items for validation should be shown or
described. It is the operators decision whether to include with the scope of validation submission
the full selection process, or to provide the description of the selection process along with the
validation deliverable.

4.6.1.3 Relevant codes and standards identification


Relevant codes and standards should be identified for each safety-critical element. The link
between the selected item and the code or standard to be applied should be clearly stated in the
scope of validation.
Codes and standards should be properly identified by their correct name, reference number, and if
applicable, edition or revision. Where no edition or revision is stated it is generally assumed that
the most recent version of the code or standard will be used. However, to remove any ambiguity it
is recommended that the version to be used is specified.

4.6.1.4 Validator selection process, independence and competence


The scope of validation should contain demonstration of the selection criteria for the validator,
their competence in all aspects that are to be validated, and their independence.

4.6.1.5 Appropriateness of the codes and standards


The scope of validation should provide instruction to the validator to determine, as part of the
validation process, that the code(s) and/or standard(s) selected are appropriate to the safetycritical system being validated.

4.6.1.6 Clearly defined deliverable


The expectations for the validation deliverable should be captured when the scope of validation is
agreed. If NOPSEMA and the operator are clear on what is expected by way of the validation,
then the validation deliverable may be limited to a simple statement by an independent,
competent validator to the effect that:

for all safety-critical elements covered by the agreed scope of validation the design,
construction and installation codes and standards applied in relation to a facility are
appropriate; and

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that if these codes and standards are used then the design, construction, and installation of
the facility will incorporate measures that will protect the health and safety of persons at
the facility and are consistent with the formal safety assessment for the facility, where
appropriate.

Alternatively the validation deliverable may be in the form of a report or certificate for each of the
elements identified by the scope of validation, see discussion in section 4.8.
Within the deliverable the validator should record, as a minimum:

if the safety-critical elements validated will be designed, constructed and installed as per
the identified code or standard;

any omissions between the agreed scope and the deliverable;

any restrictions or reservations the validator has placed on the outcomes;

whether free access was given to all data requested in the course of the validation; and

that the validation complies with Regulation 2.40 of the OPGGS(S) Regulations.

It should be noted that any restrictions or conditions placed on the outcomes of the validations
may impact on NOPSEMAs decision-making in relation to safety case acceptance.
Section 4.8 discusses the different types of deliverable in more detail.

4.6.2 Lifecycle stages


As discussed above, the scope of validation must be aligned to the facility type and the stage in the
life of the facility for which safety case acceptance is being sought. It should be noted that the
Regulations state that a safety case is not required for construction or modification of a facility at a
location that is not in Commonwealth waters, e.g. at a remote shipyard. In this instance, the types
of safety cases submitted, and consequently, the related validation, would be affected.
For example, consider validation for an FPSO project. An FPSO and related subsea equipment
(including well(s)) may make up a facility. Typically the component parts of the facility are
constructed at remote locations outside Australian waters, and therefore a safety case for the
construction stage in the life of the facility (i.e. the whole development) is not required. In order to
operate in Australia, the facility would simply require a safety case for:

the installation stage in the life of the facility, i.e. for the installation of these component parts
at the location within Commonwealth waters where they are to be used; and

a safety case for the operations stage in the life of the facility.

The operator of the FPSO facility is free to decide how many stages in the life of the facility a safety
case provides for.
An installation safety case for an FPSO would normally cover the installation of the riser and
mooring system, flowlines, manifolds and other subsea equipment.
If an operator chooses to submit several scopes of validation for agreement at the same time, they
should ensure that it is clear which scopes of validation will relate to which safety case submissions.

4.6.3 No subsequent additions


The expectation is that there should be no second bite at the scope of validation agreement. Once
the scope is agreed, it is preferable if there are no subsequent additions. If the selection of
elements subject to validation is based on sound principles, then it is not envisaged that, on

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submission of the facility safety case, there would be major misalignment between the elements of
the scope of validation agreed and the subsequent FSA, see discussion in section 4.6.5.
It is however recognised that there may be circumstances where the design of a proposed facility is
changed, or not adequately described by the operator, after agreement of the scope of validation.
NOPSEMA therefore reserves the right to request changes to the scope of validation agreed, albeit
only in exceptional circumstances. Therefore, if at any stage it becomes clear to NOPSEMA or the
operator that an item which is safety-critical should have been included within the scope of
validation proposed by the operator and agreed by NOPSEMA, NOPSEMA may choose to take one
of the following options:

request a validation under subregulation 2.40; or

request further written information as part of the safety case assessment process such
that an equivalent level of assurance, to that required by subregulation 2.40(4), is
obtained; or

reject the safety case for the facility for which activities associated with this safetycritical equipment are contemplated.

The approach taken will depend on the significance of the omitted scope item.

4.6.4 Appropriate standards


It should be noted that for those safety-critical elements of a facility which are included in the
agreed scope of validation, there should be a statement by the validator with respect to the
appropriateness of the standards relevant to each of the elements. NOPSEMA should ensure that
the operator is aware of this when agreeing the scope of validation.

4.6.5 Consistency with the FSA


For a proposed facility, the legislation requires that validation be consistent with the FSA for the
facility. Operators typically conduct coarse HAZID workshops early in the design stage, and use
output from these to identify safety-critical elements of the facility that will ultimately be subject to
validation. This should result in safety-critical elements, i.e. those that form barriers to major
accident events, being properly identified, included in the scope of validation and ultimately
validated against appropriate standards.

4.6.6 Marine Classification Certificates


It is likely that some of the features of marine vessels, Floating Production, Storage and Offloading
vessels (FPSO), FSOs, accommodation barges, Mobile Offshore Drilling Units (MODUs), pipe lay
barges, etc that are facilities under the Offshore Petroleum and Greenhouse Gas Storage Act 2006
(OPGGSA), would be subject to a form of validation by a reputable classification society at the time
of design and construction, and subsequently on an ongoing basis, resulting in marine/class
certificates being issued for the vessel.
If such a vessel is a proposed facility under Clause 4 of Schedule 3 to the Act, then the operator of
such a facility may be requested to provide a validation, as mentioned earlier and as detailed in
OPGGS(S) Regulation 2.40. The OPGGS(S) Regulations require NOPSEMA and the operator to agree
the scope of validation for the facility, prior to submission of the safety case for the facility. As part
of this agreement, NOPSEMA should ensure that the operator understands what is expected by
way of the validation deliverable. In general terms, the validation must:

address all elements of the agreed scope of validation; and

be compliant with OPGGS(S) Regulation 2.40, and be supported by information with respect to
the validator, in accordance with OPGGS(S) subregulation 2.40 (5).

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The operator of a facility for which a validation is requested, and that is subject to marine
classification, may claim that the class certification serves to address the validation requirement,
(i.e. satisfy the requirements of OPGGS(S) subregulation 2.40 (2) or 2.40 (3) and (4)), for the facility,
assuming that the validator meets the requirements of OPGGS(S) subregulation 2.40 (5). However,
typically class certificates do not adequately address all of the safety-critical elements requiring
validation and therefore often represent only part of the overall validation package.
In addition, compliance with OPGGS(S) subregulation 2.40 (5) must be separately established
including competence, access to data, ability to form an independent opinion. Typically marine
vessel classification societies include organisations such as Lloyds Register, DNV, ABS or BV and are
members of the International Association of Classification Societies (www.iacs.org.uk).
It should be recognised that the class certification of a vessel may not apply to all elements of that
vessel, but be limited to certain marine aspects. Alternatively, as is sometimes the case with
MODUs, the class certification may extend to include certain aspects of the drilling equipment.
Further, it should be recognised that some class certification is against old or outdated codes, that
have since been replaced by newer codes or standards that provide for better safety outcomes.
When setting out to agree a scope of validation for facilities subject to marine classification, it is
useful for NOPSEMA to be aware of the extent and type of marine classification certification that is
applied. This discussion must occur at the scope of validation agreement stage and can only come
from direct discussion with the operator. NOPSEMA inspectors should request the operators of
such facilities to explain, clarify and provide documentary evidence as required, in order to
determine the extent and appropriateness of the marine classification certification in the context of
validation.
When agreeing the scope of validation for facilities subject to marine classification, the marine
classification certification may be accepted as providing the reasonable level of assurance that
those elements of the vessel to which they apply incorporate measures to protect the health and
safety of the facility, as required by the Regulations.
However, where outdated or otherwise inappropriate codes or standards are applied, NOPSEMA
may not agree to the proposed scope of validation and may request that the facility is validated
against newer more appropriate codes or standards.
For a proposed facility of this type, it may be preferable for the operator to engage an independent
competent third party validator to consider all of the identified safety-critical elements of the
facility, and to form a view on the likelihood that the proposed facility will be able to meet
compliance with appropriate codes, standards and class rules. This is particularly pertinent to older
vessels that are about to enter the regime for the first time and that may carry classification against
older codes and standards.
In this way, the validation deliverable may be restricted to a simple certificate or statement from an
independent validator, rather than a collection of marine certificates, supported by validator
statements with respect to the elements of the vessel identified in the scope that are not covered
by marine certification.
In summary, in agreeing the scope of validation, NOPSEMA should discuss with the operator the
extent of the marine classification certificates, the appropriateness of those codes and standards,
and the elements of the design, fabrication and construction of the vessel to which they apply.

4.6.7 Validation and Diving Spreads


Experience has shown that portable saturation diving systems have more hardware and equipment
issues, from a safety viewpoint, than do permanently installed diving systems. Permanently
installed diving systems are usually built to class society rules and maintained in class with a
classification society. Portable systems are not commonly in class, whereas those installed
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permanently in Diving Support Vessels (DSVs) are usually in class with the same classification
society as the vessel classifying society though not necessarily so.
Diving systems that are maintained in class have additional ongoing third party verification over
and above what most diving companies and vessel companies provide for with portable diving
systems; such as:

Class must be involved in the installation;

Periodic surveys;

Any changes must be agreed to by Class; and

Maintenance of comprehensive certification for all elements of the system.

As mentioned earlier, operators of proposed facilities planning to enter the regime will be subject
to the validation requirements of the regulations, and the scope of validation must be agreed
before submitting the safety case for the facility. Where these proposed facilities have diving
systems installed, the diving system should also be included in the scope of validation.
Where an operator proposed to install a saturation diving system on an existing facility then this
modification constitutes a significant change (or modification) triggering a safety case revision, and
hence will be subject to validation.
Diving systems that are designed, built and maintained in class should be able to meet the
requirements for validation. Diving systems that are not maintained in class with a classification
society may require closer scrutiny with respect to validation and will be considered on a case-bycase basis. Operators intending to install diving systems on existing facilities should engage with
NOPSEMA at the earliest opportunity to discuss the validation expectations.

4.6.8 Validation of Well Testing Equipment


The proposed installation on a facility of well test equipment, generally including such items as
process separators, surge tanks, steam generators, choke manifolds and high pressure piping, is
deemed to constitute a proposed modification within the scope of OPGGS(S) subregulation 2.30
(1)(b)(ii) thereby triggering a requirement for a revision of the facility safety case.
Similarly, such a proposed modification is deemed to be within the definition of significant change
stipulated within OPGGS(S) subregulation 2.40 (1)(b) thereby enabling NOPSEMA to require the
operator to provide a validation in respect of the proposed significant change to the facility. As a
matter of policy, NOPSEMA has determined that it shall request a validation in every such instance.

4.7

The Validator
OPGGS(S) subregulation 2.40 (5) requires that the operator submits information on the validator in
addition to the actual validation. An operator may choose to incorporate such material into the
validation deliverable, however it should be recognised that it is beneficial to the operator for
NOPSEMA to be assured of the validators independence, competency and ability, and that he/she
will have appropriate access to data, prior to the validation being delivered. This may therefore be
included in the scope of validation and submitted to NOPSEMA for agreement.
Note that OPGGS(S) subregulation 2.40 (5) relates to a person who undertakes validation. This is
taken to mean both the individual(s) and the validation organisation.
The following subsections indicate the information which the operator may be expected to provide
in order to satisfy subregulation 2.40 (5).

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4.7.1 Competence and ability


The operator must satisfy NOPSEMA that each person who undertakes the validation is competent
and able to do so. The operator may demonstrate this by:

describing the process for the operators selection of the validator(s);

describing the operators competency criteria for validator(s); and

assessing the competency of the validator(s) against the above criteria.

4.7.2 Access to data


The validator should confirm in his report that he has had sufficient access to the necessary
information to allow him to make his decision.

4.7.3 Independence
The validator must be sufficiently independent to form an impartial opinion on the matter. The
operator may demonstrate this by providing:

evidence of the validator being, or being employed by (in the case of an individual), an
independent organisation which was not involved in the design, manufacture, construction or
installation of the equipment being validated (e.g. validation certificate issued through Lloyds
or ABS); and

evidence of the validator being, or being employed by (in the case of an individual), an
organisation separate to the operator (e.g. a copy of the validation contract between the
validator, or validators organisation and the operator); or

if the validator is directly employed by an organisation providing validation and design (or
fabrication or installation) services:

documentary evidence that the company has not been involved in the design, fabrication
or installation of the validated equipment; and

a written statement from the validator confirming his independence (e.g. that he was not
involved in the design, fabrication or testing of the validated equipment and that he was
not under pecuniary or any other pressure to produce positive validation).

Note: a validator working for an operator or an organisation involved in the design, fabrication or
installation of the validated equipment (even if the validator is working in a unit separate to the
design, fabrication or installation division, department or branch etc), is not considered sufficiently
independent.

4.8

The validation deliverable


It could be envisaged that the validation may be delivered in two forms:
1.

For proposed facilities, or for significant changes to existing facilities, with a clearly identified
scope of validation, the validation deliverable may be in the form of a report containing a
statement or set of statements, indicating that:

for the safety-critical elements of the facility selected for validation the design,
construction and installation codes and standards applied in relation to a facility are
appropriate; and

that if these codes and standards are used then the design, construction, and
installation of the facility will incorporate measures that will protect the health and
safety of persons at the facility and are consistent with the formal safety assessment for
the facility, where appropriate.

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2.

For more complex facilities a two tier validation approach may be used with the submission of
a validation report containing:

a section with the specific items and areas being validated, and certification/validation
reports issued, by discipline validators (e.g. pressure equipment validators); and

another section with the lead validators report providing an overall validation with
respect to the agreed scope of validation (based on the certification and validation reports
issued by the discipline validators) as per regulation 2.40.

Initial discussions with the operator and NOPSEMA may agree that only the lead validators report
needs to be submitted for review subject to the discipline validators reports being available for
review if requested. It is important to note that the validation delivered to NOPSEMA must satisfy
the requirements of the legislation, i.e. OPGGS(S) subregulation 2.40 (2), 2.40 (3), and 2.40 (4).
No conditions: NOPSEMA, as a matter of policy (except for exceptional circumstances), does not
grant conditional acceptances of safety cases. As a review of the validation is one of the factors to
be considered in making a decision on safety case acceptance, it follows that any conditions in a
validation submission would mean NOPSEMA would not be able to accept the safety case.

Definitions
The definitions relating to this Guideline are in the Glossary N-09000-GL0326 (Objective ID
reference: A15541).

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Validation

Other Matters

6.1

Validation of different facility types:

Type of facility
Large fixed
platform

New FPSO
facility (note
facility extends
to include
subsea
equipment)

Activities
considered

Safety Case

Validation and Other Issues

In-situ
installation of
jacket

Platform
Installation Safety
Case.

Validation of any safety-critical elements


associated with MAEs identified for the
installation of the jacket and for subsequent
use of the jacket (i.e. structural integrity),
e.g. Validation of pile driving, launching off a
barge etc.

Installation of
topsides, non
hydrocarbon
commissioning

Platform
installation Safety
Case. Note may be
same document as
above or may be a
formal revision to
the above
document.

Validation of any safety-critical elements


associated with MAEs identified for the
installation of topsides and for subsequent
use of the topsides (i.e. process integrity),
e.g. validation of lifting equipment, platform
structure, process equipment, etc.

Operations,
including
hydrocarbon
commissioning

Platform
Operations Safety
Case. May be a
revision to the
above Installation
Safety Case or a
new Safety Case if
the submission is
to address all of
the above activities
i.e. multiple stages
in the life of the
facility.

If this is a new safety case submission,


validation of the design, construction and
installation of the identified safety-critical
elements of the facility is required to be
complete.
If this is a revised safety case just for the
operations stage in the life of the facility,
then validation should have been
appropriately addressed during previous
safety case submission(s).
Separately, and as a content requirement of
the safety case, the operator should
describe how the operator ensures that
safety-critical elements will be variously fit
for purpose, or fit for its function and use,
for the operations stage in the life of the
facility.

Installation of
subsea
equipment,
moorings risers,
etc

Installation Safety
Case.

Validation of safety-critical elements relative


to the installation stage in the life of the
facility and for subsequent use of this
equipment.

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Type of facility

Old MODU, new


to Australian
waters

Activities
considered

Safety Case

Hook up of
subsea
equipment to
floating buoy,
arrival of FPSO
and nonhydrocarbon
commissioning

Installation Safety
Case.
Note may be same
document as above
or may be a formal
revision to the
above document.

Validation of the balance of the identified


safety-critical elements.

Hydrocarbon
commissioning
and operations

Operations Safety
Case. Considered a
formal revision to
the above
Installation Safety
Case or a new
Safety Case if the
submission is to
address all of the
above activities i.e.
multiple stages in
the life of the
facility.

If this is a new safety case submission,


validation of the design, construction and
installation of the identified safety-critical
elements of the facility is required to be
complete.
If this is a revised safety case just for the
operations stage in the life of the facility,
then validation should have been
appropriately addressed during previous
safety case submission(s).
Separately, and as a content requirement of
the safety case, the operator should
describe how the operator ensures that
safety-critical elements will be variously fit
for purpose, or fit for its function and use,
for the operations stage in the life of the
facility.

General drilling
operations

Operations Safety
Case.

Validation of the design, construction and


installation of the identified safety-critical
elements of the facility is required to be
complete.
Separately, and as a content requirement of
the safety case, the operator should
describe how the operator ensures that
safety-critical elements will be variously fit
for purpose, or fit for its function and use,
for the operations stage in the life of the
facility.

Validation and Other Issues

Marine certification may apply to some of


the identified safety-critical elements of the
facility.
Validation of safety-critical elements of the
facility that are not covered by Class
certificates, and any modifications made in
shipyard, need to be taken into
consideration.
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Validation

Type of facility

Activities
considered

Safety Case

Validation and Other Issues

Existing MODU
working in
Australian
waters

Temporary,
recurring,
modifications well testing

Formal revision to
existing Operations
Safety Case in
force.
Note installation of
well test
equipment is
deemed to be a
significant change
to an existing
facility, thereby
triggering a
revision.

Validation of the design, construction and


installation of the significant change (the
well test equipment) is required to be
complete.
Separately, and as a content requirement of
the safety case, the operator should
describe how the operator ensures that
safety-critical elements will be variously fit
for purpose, or fit for its function and use,
for the operations stage in the life of the
facility.

Marine vessel
undertaking
construction /
installation
activities

Installation of
the component
parts of a host
facility, e.g.
vessel installing
subsea
elements of an
FPSO
development.

Operations Safety
Case.

Validation of the design, construction and


installation of the identified safety-critical
elements of the facility is required to be
complete.
Separately, and as a content requirement of
the safety case, the operator should
describe how the operator ensures that
safety-critical elements will be variously fit
for purpose, or fit for its function and use,
for the operations stage in the life of the
facility.
Marine certification may apply to some of
the identified safety-critical elements of the
facility.

Pipelines in
Commonwealth
Waters

Design,
construction
(e.g. welding)
and laying of
the pipeline.

Construction and
Installation Safety
Case.

Validation of the design, construction and


installation of the identified safety-critical
elements of the facility is required to be
complete. That is, despite the fact that
there may be few (if any) MAEs identified
for the construction and installation stage in
the life of a pipeline, the validation must
address the safety-critical elements of the
pipeline facility for the operations stage in
the life of the pipeline. This is because
Regulation 2.40(1) only allows NOPSEMA to
require a facility operator to provide a
validation in respect of a proposed facility or
a proposed significant change to an existing
facility (e.g. generally modification or
decommissioning). Consequently, once a
pipeline has been constructed and installed,
there is generally no legal provision for
NOPSEMA to request a validation of a
proposed significant change.*

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* Note: In this context, a proposed significant change to an existing facility is generally considered to be a
modification or decommissioning. The only exception to this is in circumstances where a facility may
have been designed to meet certain requirements, but at the point of initial safety case submission the
operator did not contemplate the activity for which the facility was designed.

Critical Success Factors

The success of this process depends on agreeing a scope of validation that is both effective and
deliverable.

The validation must be aligned with the scope of the safety case that is going to be submitted
for assessment subsequent to the agreement.

Early engagement with the operator, and the validator, is beneficial to ensure that what is
delivered to NOPSEMA clearly satisfies the legislative requirements.

There should be a clear view of what treatment is required for each element, such that an
unconditional validation report can be provided in a reasonable time frame, and assurance
about other matters that require verification are adequately covered in the safety case.

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